Privacy Policy | Cavago Chat on WhatsApp

Privacy and Cookies Policy

Last Updated: 4 October 2019

Cavago Pte. Ltd. ( "we" "us" or "our", as the context may be) are committed to protecting and respecting your privacy. This Privacy and Cookies Policy (together with our Terms & Conditions describe our practices related to the processing of personally identifiable information we collect from or about you in the course of your use of MyCavago.com and our mobile websites ( “Cavago Platform”).

1. About us

The Cavago Platform is owned and operated by Cavago Pte. Ltd. with its registered office at 1 Keong Saik Road, Unit 10 – The Working Capitol, Singapore 089109. You can contact us:

(a) By post,

(b) Using our website contact form;

(c) By telephone, on the contact number published on our website from time to time; or

(d) By email, using the email address published on our website from time to time.

2. How this Privacy and Cookies Policy applies

This Privacy and Cookies Policy applies where we are acting as a data controller with respect to your personal data as a visitor of our website and/or user of our services; in other words, where we determine the purposes and means of the processing of that personal data.

We will only process your personal data in the manner set out in this Privacy and Cookies Policy if you have specifically agreed or consented to us doing so (for example through your explicit acceptance of this Privacy and Cookies Policy or via an electronic tick-box or other similar measures as required by applicable data protection laws) or if we have legitimate grounds to do so.

3. The personal data that we may collect

3.1 Information you give us.

Information that is necessary for the use of the Cavago Platform.

We ask for and collect the following personal information about you when you use the Cavago Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

Information you choose to give us

You may choose to provide us with additional personal information in order to obtain a better user experience when using Cavago Platform. This additional information will be processed based on your consent.

3.2 Information we collect about you

When you use the Cavago Platform, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Cavago Platform.

3.3 Information we receive from other sources.

We may collect information, including personal information, that others provide about you when they use the Cavago Platform, or obtain information from other sources and combine that with information we collect through the Cavago Platform. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

We will combine the information that we collect automatically from you with any other information that we collect directly from you or about you (see “Aggregate data, data analytics and social media functionality” below).

From time to time we may update the methods of collection and data fields above. Where there are significant changes we will endeavour to notify you in accordance with the section "Notification of changes to this Privacy and Cookies Policy" below.

4. How we use personal data?

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Cavago Platform, create and maintain a trusted and safer environment and comply with our legal obligations.

4.1 Provide, improve and develop the Cavago Platform

4.2 Create and Maintain a Trusted and Safer Environment.

We process this information given our legitimate interest in protecting the Cavago Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

4.3 Provide, Personalise, Measure, and Improve our Advertising and Marketing.

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Cavago Account.

5. Sharing and disclosure

5.1 With Your Consent.

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorise a third party application or website to access your Cavago Account or when you participate in promotional activities conducted by Cavago partners or third parties.

5.2 Sharing between Members.

To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:

We don’t share your billing and payout information with other Members.

5.3 Profiles, Listings, and other Public Information.

The Cavago Platform lets you publish information, including personal information, that is visible to the general public. For example:

Based on our legitimate interest to promote the Cavago Platform we may display parts of the Cavago Platform (e.g., your Listing page) on sites operated by Cavago’s business partners, using technologies such as widgets or APIs. If your Listings are displayed on a partner’s site, information from your public profile page may also be displayed.

Information you share publicly on the Cavago Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

5.4 Additional Services by Hosts.

Hosts may need to use third party services available through the Cavago Platform to assist with managing their Facility or providing additional services requested by you, such as photography services, equestrian insurance. Hosts may use features on the Cavago Platform to share information about the Guest (like check-in and check-out dates, Guest name, Guest phone number) with such third party service providers for the purposes of coordinating the stay, managing the Facility, or providing other services.

5.5 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Cavago, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Cavago, its employees, its Members, or members of the public.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Cavago Platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Cavago’s property, its Members and the Cavago Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after Page 7 of 14 the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

5.6 Working with other service providers

For operational reasons, insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy and Cookies Policy, we transfer personal data to service providers who help us manage our systems and processes (including without limitation market analytics), and to deliver our services to users.

We have implemented safeguards to ensure that our service providers treat personal data in a way that is consistent with the terms of this Privacy and Cookies Policy and applicable laws, and that it is not used except to fulfil products or services to us or where we believe it is necessary for a legitimate reason connected with the products or services we offer.

These service providers and group companies may be located in your country, countries in the European Economic Area, in the United Arab Emirates or elsewhere in the world. Different privacy laws may apply in these countries. See further detail in our "Transfer of Personal data" section below.

5.7 Social Media Platforms.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Cavago Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal data are not controlled or supervised by Cavago. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider. Please note that you may, at any time ask Cavago to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@mycavago.com

5.8 Collection and Remittance of Occupancy Taxes.

In jurisdictions where Cavago facilitates the collection and remittance of occupancy taxes as described in the “Taxes” section of the Terms, Hosts and Guests, where legally permissible according to applicable law, expressly grant us permission, without further notice, to disclose Hosts’ and Guests’ data and other information relating to them or to their transactions, bookings, facilities and occupancy taxes to the relevant tax authority, including, but not limited to, the Host’s or Guest’s name, Listing addresses, transaction dates and amounts, tax identification number(s), the amount of taxes received (or due) by Hosts from Guests, and contact information.

5.9 Business Transfers.

If Cavago undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

6. Your rights

We have summarised some rights that you may have under applicable data protection law. You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

You (may) have the following rights:

(a) The right to access;

(b) The right to rectification;

(c) The right to erasure;

(d) The right to restrict processing;

(e) The right to object to processing;

(f) The right to data portability;

(g) The right to complain to a supervisory authority; and

(h) The right to withdraw consent.


You may exercise any of your rights in relation to your personal data by written notice to us.

6.1 Managing your information

You may access and update some of your information through your Account settings. If you have chosen to connect your Cavago Account to a third-party application, like Facebook or Google, you can change your settings and remove permission by changing your Account settings. You are responsible for keeping your personal information up-to-date.

6.2 Access to your personal data

You may have the right to confirmation as to whether or not we process your personal data and, where we do, receive a copy of personal data we keep about you, including the sources of the data, the purposes and methods of processing, any electronic decision-making and the entities with whom we share your data. We will endeavour to provide the information you require within a reasonable time. There may be a small monetary charge for some requests, depending on the information requested, to the extent permitted by applicable law.

6.3 Correction/updating of personal data

If your personally identifiable information changes or is inaccurate, we will provide a way to correct, update or suppress your personal data provided to us. If you are concerned that any of the information we hold about you is incorrect, please contact us. These rights are without prejudice to any legal rights you may have in applicable laws, including your right to object to certain processing of data.

6.4 Erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Cavago Platform to you, you can request that we erase your personal information and close your Cavago Account. Please note that if you request the erasure of your personal information:

6.5 Restriction to processing

You may have the right to restrict the processing of your personal data when (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

6.6 Objection to processing

Unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims, you may have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: (i) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or (ii) the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data.

You may have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You may have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

6.7 Data portability

To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means;

you may have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

6.8 Complaint to a supervisory authority

If you consider that our processing of your personal data infringes data protection laws, you may have a legal right to lodge a complaint with the relevant supervisory body responsible for data protection.

6.9 Withdrawing your consent

To the extent that the legal basis for our processing of your personal data is consent, you may have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You do not have to provide us with your personal data. However, if you choose not to provide certain personal data we request and/or require, or consent to its use and disclosure, you will still be able to visit the Cavago Platform but you may be unable to access certain options, products or services.

You also have the ability to change your cookie settings to block certain types of cookie - this is explained in more detail in our Cookie Policy.

7. Operating globally

To facilitate our global operations Cavago may transfer, store, and process your information in countries outside Singapore. Laws in these countries may differ from the laws applicable to your country of residence. BY GIVING YOUR CONSENT, YOU UNDERSTAND AND UNAMBIGUOUSLY AGREE THAT YOUR INFORMATION MAY BE PROCESSED AND STORED IN THESE JURISDICTIONS AND THAT DIFFERENT PRIVACY LAWS MAY APPLY IN THESE COUNTRIES WHICH MAY NOT ENSURE THE SAME LEVEL OF DATA PROTECTION AS GRANTED IN YOUR COUNTRY OF RESIDENCE.

We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws. Where required under applicable laws we will take measures to ensure that personal data handled in other countries will receive at least the same level of protection as it is given in your home country.

We comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ .

If we have received your personal information under the Privacy Shield and subsequently transfer it to a third party service provider for processing as described in this Privacy Policy, we will remain responsible if these providers process your personal information in a manner inconsistent with the Privacy Shield Principles, except where we can establish that we were not responsible for the violation.

In the event your personal data is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions but we will only do so where required by applicable laws.

8. Security

We will take appropriate steps to protect the personal data you share with us. We have implemented technology and security features to safeguard the privacy of your personal data. We invest significant resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

9. Aggregate data, data analytics and social media functionality

We may aggregate personal data and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Platform use, to improve our content and product offerings, and to customise the Cavago Platform’ content, layout, products and services, and we may appoint third parties to do this on our behalf, as set out above.

We gather certain usage information like the number and frequency of visitors to the Cavago Platform. This information may include which webpage you just came from, which webpage you next go to, what browser you are using, your device and your IP address. We only use such data in the aggregate. This collective data helps us to determine how much our customers use parts of the Cavago Platform, and do research on our users’ demographics, interests, and behaviour to better understand and serve you.

If you use buttons on the Cavago Platform linked to social media or similar sites (for example "Like" and/or "Share" buttons), content from the Cavago Platform may be sent back to that other website or service and, depending on your privacy settings, may be privately or publicly visible (for example to friends, followers or generally to anyone who has access to your profile page).

10. Retaining and deleting personal data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained.

Notwithstanding the above, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject.

11. Cookies and other tracking technologies

We use cookies on our website. A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate the Cavago Platform and the Internet and helps us provide better Platform services to you and tailor certain content. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies. Insofar as those cookies are not strictly necessary for the provision of our website, products and services, we will ask you to consent to our use of cookies when you first visit our website. Not accepting these cookies may affect your use of the Cavago Platform.

11.1 Types of Cookies

The Cavago Platform uses both session and persistent cookies, and first and third-party cookies.

Session cookies exist just for your session on the Cavago Platform and persistent cookies exist for a longer period and are activated each time you visit the Cavago Platform. First party cookies are cookies set by the Cavago Platform and third-party cookies are set by third party Cavago Platform.

We also use cookies for different purposes. To assist you, we've provided a more detailed explanation of the types of cookies we use below categorised by the purpose of the cookies.

Functional Cookies - these are cookies that are essential for the operation of the Cavago Platform. They include, for example, cookies that enable you to log into secure areas of our websites, progress or complete a booking or make use of other online services we provide. If you disable these cookies, then you may not be able to use the Cavago Platform fully or at all.

Analytical/performance cookies – these allow us to count the number of visitors and to see how visitors move around the Cavago Platform. We aggregate this data and analyse it to improve the way the Cavago Platform work and the user experience, for example, by improving the Cavago Platform’ layouts. We use trusted third-party analytics providers’ tools to enable this analysis. A description of the use of this information is set out in the "Aggregate data, data analytics and social media functionality" section of our Privacy Policy.

Local Storage Objects - we may use Flash Local Storage Objects (“Flash LSOs”) to store your Platform preferences and to personalise your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

11.2 How to reject and/or delete cookies

Modern browsers allow you to change your cookie settings. You can set your browsers or devices to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. The last of these means that certain personalised features cannot then be provided to you and accordingly you may not be able to take full advantage of all of the website's features. Each browser is different, so check the ‘help’, 'options' or 'preferences' menu of your browser to learn how to change your cookie preferences.

You can also visit http://www.aboutcookies.org/ (opens in a new tab) which contains comprehensive information on how to do this on a wide variety of browsers. This site includes details on how to delete cookies from your computer as well as more general information about cookies.

Please also note that if you delete your cookies, unless you were required to provide explicit consent, we may no longer automatically recognise that you have agreed to our Privacy Policy, this Cookies Policy and any other website terms of use, and we may ask for confirmation of this along with your language and country preferences.

In relation to advertising cookies, if you are in the EU you can use the YourOnlineChoices.eu (opens in a new tab) website which allows you to set which advertising cookie providers you accept, and which you do not.

11.3 Useful links

The following website gives information specifically about privacy (opens in a new tab) issues around Internet advertising: YourOnlineChoices.eu (opens in a new tab) - as referred to above this allows you to set which advertising cookie providers you accept.

11.4 Do Not Track

Currently, our systems do not honour browser do-not-track requests; you may delete cookies and other tracking technologies using the processes specified in our Cookie Policy.

11.5 Links

The Cavago Platform may contain links to other websites. Please be aware that we are not responsible for the privacy practices of web sites not operated by us. We encourage you to read the Privacy and Cookies Policies of each and every website that collects personally identifiable information. This Privacy and Cookies Policy applies solely to information collected by the Cavago Platform.

12. Notification of changes to this Privacy and Cookies Policy

If we decide to change our Privacy and Cookies Policy, we will post those changes on the Cavago Platform. If at any point we decide to use personally identifiable information in a manner materially different from that stated at the time it was collected (and/or where we are required under applicable law) we will notify you. You will have a choice as to whether or not we use your personal data in this different manner. We will use personal data in accordance with the Privacy and Cookies Policy under which the personal data was collected until you agree otherwise, but if you do not accept the amended Privacy and Cookies Policy, please stop using the Cavago Platform. Each version has a version number and date so you can check this easily.

13. Contact

If you experience any technical problems during your interaction with the Cavago Platform, please contact us here: cavago@mycavago.com

Queries, concerns or complaints regarding your privacy or this Privacy and Cookies Policy: If you have queries regarding this Privacy and Cookies Policy please contact us as follows:

Data protection officer: Tauseef Qadri Email address: cavago@mycavago.com Telephone number: +65 6813 2110